October 27, 2025
The Serious Fraud Office has achieved its first successful deployment of a UWO against Ms Schools, in a case that underscores the growing strategic value of civil recovery powers under POCA. Key insights in this month’s FOCUS examine:
-Although Ms Schools was not accused of participating in her former husband’s fraud, the High Court found that her legitimate income could not account for the purchase of a £430,000 property—funded through proceeds ultimately traced to the Axiom fraud. The judgment confirms that connection to serious crime, even without direct involvement, can satisfy the statutory criteria for a UWO.
-This case reflects a broader shift in enforcement strategy, supported by the Economic Crime (Transparency and Enforcement) Act 2022, which now protects agencies from adverse cost orders unless misconduct is proven.-With UWOs placing the burden of explanation on the respondent, they are poised to become a more prominent tool in tackling complex financial concealment and recovering illicit assets.-The NCA secured the first UWO in 2018 against Zamira Hajiyeva, known for extravagant spending at Harrods. Her appeal failed, and in 2024 she forfeited a £14.75 million Knightsbridge home and a golf course. The second UWO, issued in 2020, targeted Mansoor Hussain, suspected of laundering money for Bradford-based crime gangs.-Barristers advising on POCA matters should anticipate increased reliance on UWOs—not only as standalone instruments but in tandem with prosecution, confiscation and civil recovery proceedings.Read latest FOCUS here: https://redlionchambers.substack.com/p/mcmafia-revisitedOctober Focus authors: Ed Vickers KC and David Claxton